Esteemed author and attorney, Gerald M. Levine noted, "When dictionary words are misspelled in a domain name[,] the inference is persuasive that the respondent had actual knowledge of the trademark targeted," in his article referencing the Naughty America WIPO decision. udrpcommentaries (September 13, 2010).

The WIPO Panel concluded that the domain names contained intentional misspellings of the well-known NAUGHTY AMERICA® trademark and ordered that the domains be transferred to Naughty America. WIPO Case No. D2010-1118.